520 



References 



1. Guidelines for Sea Disposal Packages of Radioactive Waste-NEA, OECD, 

 Paris, France, November, 1974. 



2. Weast, R. C, Ed., CRC Handbook of Chemistry and Physics , 59th Ed, CRC 

 Press, 1978. 



3. Joseph, A. B., "United States' Sea Disposal Operations: A Summary to 

 December 1956," WASH-734 , August 1957. 



4. The Ocenaographic Basis of the IAEA REvised Definition and Recommendations 

 Concerning High-level Radioactive Waste Unsuitable for Dumping at Sea, 

 Tech. Doc. 210, IAEA, Vienna, 1978. 



5. Noshkin, V.E. at al . , "Radionuclides in the Marine Environment near the 

 Farallon Islands," UCRL-5281, January 6, 1978. 



6. National Academy of Sciences, "Radioactivity in the Marine Environment," 

 Prepared by the Panel on Radioactivity in the Marine Environment of the 

 Committee on Oceanography, National Research Council, 1971. 



Prepared Statement of Fred Eissler, Scenic Shoreune Preservation 



Conference 



Scenic Shoreline Preservation Conference is a California environmental organiza- 

 tion headquartered in Santa Barbara. We are concerned about the dumping of 

 radiological wastes in our area within the vicinity of the Channel Islands National 

 Park and Marine Sanctuary. We wish to support efforts to promote government 

 monitoring of these dumpsites and actions to control any harmful effects of the 

 radionuclides upon the marine ecology and edible fish. 



Two sites and possibly three have been utilized for radiological dumping purposes. 

 Approximately 33 miles southeast of Santa Cruz Island (33°39'N, 119°28'W) is a 

 Navy disposal area in the Santa Cruz Basin identified on navigation maps as a 

 munitions and chemical dump. Between 1946 and 1972 some 3,100 drums containing 

 108 curies of contaminated wastes were jettisoned in this area, according to availa- 

 ble reports which EPA officials indicate could underestimate the actual amount by 

 a factor of at least ten. 



A second site in the channel region (34°30'N, 122°50'W) is located 106 miles west 

 of Point Arguello, according to a reference in the Industrial Radioactive Waste 

 Disposal Hearings Record before the Special Subcommittee on Radioactive Wastes, 

 JCAE (86th Congress), page 2683. 



Possibly a third site in the Santa Barbara Basin proposed by the National Acade- 

 my of Sciences as a safer disposal area than the Santa Cruz Basin (National 

 Academy of Sciences, National Research Council "Disposal of Low-Level Radioactive 

 Waste into Pacific Coastal Water," Publication 185-1962 may have been utilized on 

 the basis on the NAS recommendation. 



The Santa Barbara County Board of Supervisors and local environmental groups 

 as well as our organization are on record in favor of surveillance of these dumpsites. 

 Scenic Shoreline addressed a letter to EPA Secretary Douglas Costle raising a 

 number of questions on this crucial issue and we would like to submit this letter for 

 your hearing record. 



It is our understanding that these and other ocean disposal areas in the nation's 

 coastal water were multiple purpose dumps. In the case of the Santa Cruz Basin 

 Naval dump, munitions wastes and chemicals besides radiologically-contaminated 

 laboratory equipment, garments, and other materials were all jettisoned in the 

 same type of 55 gallon drum making the radioactive drums somewhat more difficult 

 to identify. 



We would like to suggest since all these drums would probably be inspected to 

 identify the radioactive ones, that the monitoring program be extended to an 

 appraisal of the impact upon the marine ecosystems not only of the radiological 

 wastes but the assorted chemicals and munitions wastes to determine their toxicity 

 separately and in combination. No attention has been given to these other wastes 

 which may in some cases be as toxic or more toxic than the radiological materials 

 and could possibly have a significant synergistic effect as well. 



It was not long ago that the dumping issue received national attention with the 

 proposed disposal of nerve gases in the Atlantic Ocean. Militray dumping and the 



